1,4-dioxane: The case of the disappearing tumors

Right now, EPA is in the process of conducting “risk evaluations” for existing chemicals in commerce, as mandated by the recently passed Lautenberg Chemical Safety for the 21st Century Act (which amended the original, ineffective Toxic Substances Control Act).

[For a refresher on how this effort fits into the bigger picture of chemical assessments, you can review my infographic.]

So far, the agency has released draft risk evaluations for four chemicals: PV-29, HBCD, 1,4-dioxane, and 1-bromopropane. I’ve been working with my former colleagues at EDF Health to carefully review the drafts for the latter two chemicals.  Unfortunately, as expected, these drafts put out by the Trump EPA have a number of problems, which we’ve detailed in public comments.

For a window into one particularly concerning issue, you can check out a post that I wrote with Dr. Richard Denison on the EDF Health blog, 1,4-dioxane: The case of the disappearing tumors.

The Big Chart of Federal Chemical Evaluations & Assessments

Today, I’m excited to share an infographic that I made, depicting all of the different chemical evaluations and assessments that various federal agencies (in the U.S.) conduct.

If you want to hear about the backstory & process for creating this, read on below.

Otherwise, here’s a link to a PDF version of the graphic. There are hyperlinks throughout, if you want to explore any of the information further. Yes, I know this is very detailed; it is meant to be digested by zooming around to different sections of the graphic.

I’ve tried to be as accurate as possible. But if you catch something that doesn’t look right, please let me know.

I hope this helps the environmental health community (and others who might be interested) better understand the review processes that are intended to keep us safe (unless/until politics get in the way…).

The backstory

In April, the Agency for Toxic Substances and Disease Control (ATSDR) released a draft ToxProfile for glyphosate. If you’ve been following this blog, you know that I’ve been paying a lot of attention to glyphosate lately (see some of my recent posts here and here). Given my interest in this topic, I decided to review the document and take the opportunity to prepare public comments.

[What are public comments, you might ask? Public comments are a way for the public to provide feedback during the federal rulemaking process. Under the Administrative Procedure Act (1946), whenever a federal agency develops a new regulation, they are required to solicit input from the public. (For more on the public comment process and how you can get involved, check out the Public Comment Project!)]

As I was reviewing ATSDR’s ToxProfile, I realized that I did not fully understand how this effort was distinct from EPA’s assessment of glyphosate. ATSDR and EPA are two separate federal agencies with different missions, so clearly these assessments served different purposes.

I soon realized that elucidating this distinction was just one part of a larger story. So, I decided to create a master chart to better understand all of the different types of reviews, evaluations, and assessments that different federal agencies conduct, the main purposes of these evaluations, and what other processes or regulations they might relate to.

The process

Some of the agency assessments were quite familiar to me or fairly well-explained online; for example, those that EPA is supposed to conduct under the recently reformed Toxic Substances Control Act. It was surprisingly hard to get clear information on other assessments and related agency activities, however (even for me, someone who is relatively well-versed in this field). Specifically, I found the online information for the Occupational Safety and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH), and the Consumer Product Safety Commission (CPSC) to be a bit confusing. I actually ended up calling several people at these agencies (using phone numbers listed online) to get clarifying information. (Thank you to those federal employees who picked up my cold calls and answered my questions!)

I started collecting this information in an excel chart, but this format is not very conducive to easy online reading or sharing. So, I decided to challenge myself to make an infographic, which I had never done before. I experimented with various online tools before settling on draw.io, which I also used to make the timeline in the glyphosate meta-analysis. I’ll spare you the details, but let’s just say, this took me a LONG time (sorry, dissertation, I’ll get back to you soon).

I imagine that I’ll continue to refine this over the next few months/years. If you see anything that looks wrong or have suggestions for improvement, let me know.

Reflections on Reform

There has been no shortage of news articles and blog posts about the recent passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which amends the ineffective and outdated 1976 Toxic Substances Control Act (TSCA). And, you probably don’t need to read another description of the strengths and weaknesses of the ultimate compromise. (If you do want a quick primer on why this reform matters, though, I would recommend this NPR interview with my former boss, Richard Denison, or his post on why this is a “really big deal.“)

Nevertheless, I want to add some reflections of my own on this historic occasion.

As a student in the environmental health field, this bill is particularly significant to me. Not only does the reform directly influence issues that I think about constantly, both personally and academically, but it will also likely set the stage for my future career.

It is exciting to think that I, along with fellow classmates in toxicology, environmental epidemiology, and exposure science programs across the country, will soon be able to participate directly in the implementation of this updated chemical safety system. We can feel a new sense of possibility with our work, instead of the backdrop of futility that comes when we learn in our foundational courses that – despite the damning evidence- the Environmental Protection Agency (EPA) could not even ban asbestos(!). With that (previous) reality in mind, could there be any hope that our efforts studying other potentially harmful chemicals would ever make an impact? As an analogy, what if there were a law that prevented the Centers for Disease Control and Prevention (CDC) from implementing effective vaccination programs? How would budding infectious disease epidemiologists feel about their opportunities for contributing to real public health advancements? Now, with the Lautenberg Act, we have a new framework in place that will at least offer the chance for us to use our research to make a difference. I hope that this will inspire others to join this dynamic, interdisciplinary field.

TSCA reform will impact and energize many aspects of environmental health. For example, the new mandate for safety reviews of all chemicals in active commerce will require investment in efficient and accurate screening tools. New testing technologies are already being developed, but further work and innovation – as well as input from a diverse array of scientists – will be necessary to ensure their reliability, relevance, and validity.

In addition, this reform will likely spur more research to understand the unique susceptibility of certain populations. The bill contains provisions that explicitly require protection of “potentially exposed or susceptible population[s].” This category includes “infants, children, pregnant women, workers, and the elderly,” but also other individuals who may be “susceptible to greater adverse health consequences from chemical exposures than the general population” – for example, because of their genetics. The study of gene-environment interactions (also known as “toxicogenetics”) aims to investigate specific genes that make some individuals more sensitive to chemicals. Dr. Francis Collins, director of the National Institutes of Health, summed up this idea with the phrase “genetics loads the gun, but the environment pulls the trigger.” Toxicogenetics is already a rapidly growing field, but I anticipate future work in this area will be crucial in helping us to determine the levels at which regulations should be set to ensure protection for those who are most vulnerable.

While there will likely be numerous positive consequences of the reform bill, the success of this updated chemical policy system is far from guaranteed. Numerous roadblocks may appear, such as the possibility of a mismanaged EPA or the paralyzing impact of endless cost-benefit analyses in risk management decisions. Passing TSCA reform was a difficult and momentous task, but the hard work will continue. We must maintain pressure to hold EPA accountable, prevent entanglement by special interests, and ensure the law is executed correctly. And, Congress must provide adequate funding to environmental health research programs, which will produce key scientific evidence to guide EPA and educate the next generation of scientists (like me!).

This compromise was not perfect, but the bill does represent a real improvement over the status quo. Now, the environmental health community has an exciting chance to help make its enactment as strong as it can be, through robust research and continued advocacy.

I can’t wait to play my part.

 

Domestic legislation with international implications?

Take a look at these three world maps. Does anything stand out to you?

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For interactive versions of these maps, visit the Synergies Among the Basel, Rotterdam, and Stockholm Conventions webpage (also the source for these static images)

 

Maybe the uninspiring shade of grey that covers the United States in each one?

Yes, that’s what caught my attention as well.

These maps indicate member countries for the Stockholm Convention, the Rotterdam Convention, and the Basel Convention, respectively. The Stockholm Convention aims to eliminate or restrict Persistent Organic Pollutants, or “POPs,” which are toxic chemicals that persist in the environment and build up in organisms. The Rotterdam Convention promotes open exchange of information about specific pesticides and industrial chemicals. And, the Basel Convention focuses on the management of hazardous waste. Member countries (indicated by color coding on each of the maps above) can participate and negotiate in the relevant discussions. The United States, along with countries such as South Sudan, Myanmar, Iraq, and Uzbekistan, has not officially ratified the treaties.

The obstacle to forward movement on this issue is Congress (surprise, surprise). As with any international treaty, approval requires the “advice and consent” of two thirds of the Senate. But before this vote can take place, Congress needs to amend existing federal laws – the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the Resource Conversation and Recovery Act (RCRA) – so the U.S. is able to comply with the treaties (for example, to give EPA the authority to regulate chemicals listed). Over the years, several relevant amendments have been proposed, but none have passed..

The chemicals regulated in these treaties are among the worst of the worst – dioxins, PCBs, DDT, as well as several multi-syllabic pesticides – and they tend to migrate long distances through wind, water, and biological organisms. EPA needs to have the ability to take appropriate actions on these chemicals, and others added in the future, to protect public health and the environment.

By abstaining from the treaties, the U.S. cannot negotiate for the addition of other dangerous compounds that may pose serious health risks to our population. (These chemicals do not respect borders, and pollutants released across the world can travel and cause harm here. The Alaskan Artic region is especially vulnerable). And, although U.S. taxpayers contribute to the Global Environment Facility – a fund that provides grants to assist countries on specific environmental improvement projects, including many related to the clean-up of POPs – we have no input on the use of these funds, since we are not members of the convention.

TSCA reform is currently under negotiation in the Senate and House, and while there have been intense discussions about many key components of the bill (such as state-preemption), minimal information is available regarding potential implications for these international treaties. However, it is crucial that the final legislation include such provisions, thereby paving the way for the U.S. to participate meaningfully in discussions regarding global chemicals of concern.

Mother’s Day Ethics

A few weeks ago, I had the privilege of hearing Dr. Steven Gilbert, founder of the Institute of Neurotoxicology and Neurological Disorders and Toxipedia, give a talk entitled “The Ethics of Epigenetics.” Epigenetics, an increasingly important concept in environmental health, introduces the possibility that environmental exposures can have trans-generational impacts. That is, certain compounds may be able to alter the way in which genes are expressed, so the effects of these exposures can manifest in the children and grandchildren of the exposed population.

As a graduate student in toxicology, the idea of epigenetics was not new to me. However, Dr. Gilbert incorporated a critical ethical dimension to his discussion that was inspiring and moving. He suggested the obvious yet often not explicit enough implication of epigenetics: that it demands an altered framework for policy and action, since what we are being exposed to (most of the time, without our consent) may impact not only ourselves but also future generations.

Mother’s Day may be an especially appropriate time to think about the consequences of epigenetics. As I celebrate my mother, I can’t help but think about how her mother’s exposures may have impacted her life and her health. I wonder the same about myself: how will my life course and health be affected by my mother’s and my grandmother’s exposures to chemicals? And, similarly, what about the effects of my own exposure to unregulated chemicals on my future children? (I should note, though, that epigenetic changes can also be passed down on the paternal side.)

How can we end this cycle? What will it take to ensure that Mother’s Day can be a celebration of family health instead of a reminder of family exposures and disease?

The only real solution is reform of the nation’s severely outdated and ineffective chemical safety law, the Toxic Substances Control Act (TSCA). We need a TSCA reform that is robust and can gain bipartisan support – now. Further delay is unethical, putting ourselves and our children at risk.